Dallas Brass & Copper Co. v. Commissioner
United States Board of Tax Appeals
1. Under the Revenue Act of 1918, a corporation return for income tax is a sworn statement "stating specifically the items of its gross income and the deductions and credits allowed by this title," as set forth in section 239 of said Act. 2. The so-called tentative return, Form 1031-T, as made and filed by this taxpayer, did not state any items of gross income or deductions and was not the return required by law. 3. The time within which the Commissioner may make an…
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1. Under the Revenue Act of 1918, a corporation return for income tax is a sworn statement "stating specifically the items of its gross income and the deductions and credits allowed by this title," as set forth in section 239 of said Act. 2. The so-called tentative return, Form 1031-T, as made and filed by this taxpayer, did not state any items of gross income or deductions and was not the return required by law. 3. The time within which the Commissioner may make an assessment or assert a deficiency of income and profits taxes under the Revenue Act of 1918 is the period of five years from and…
1Opinion of the Court
Teussell:
This is an appeal from the determination of a deficiency in income and profits taxes for the year 1918 in the amount of $35,213.85. The issues presented by the pleadings are:(1) Whether a deficiency assessment made by the Commissioner on June 13,1924, was made within the five-year limitation prescribed by statute.(2) Whether the same Commissioner may, after having once made an adjustment of this taxpayer’s liability to income and profits taxes, thereafter, upon his own motion, reopen the case and assert an additional liability to income and profits taxes and assess the same within…
2Cases cited1 opinion
- Penrose v. SkinnerDistrict Court, D. Colorado · 1921
3Cited by9 opinions
- Skaneateles Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Cantrell & Cochrane v. CommissionerUnited States Board of Tax Appeals · 1930
- Couzens v. CommissionerUnited States Board of Tax Appeals · 1928
- Dallas Brass & Copper Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Estate of Lohman v. CommissionerUnited States Tax Court · 1972
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